Changes and Results from First PBJ Submission

Mar 30, 2017 | Rules for PBJ Reporting, Five Star Staffing Ratings

News Digest: Changes and Results After First PBJ Submission

With the first full PBJ reporting period over, and 90%+ facilities successfully submitting a PBJ report – CMS identified data and technical issues to clean up.  Those changes came through in a new Policy Manual and FAQ.  Meanwhile the industry found some areas of PBJ reporting that could merit a change.

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CMS urges more provider diligence on PBJ data

Skilled nursing providers should submit their next round of payroll based journaling data well ahead of the May 15 deadline in order to catch errors, Centers for Medicare & Medicaid Services officials said Thursday.

CMS staff told attendees of the Skilled Nursing Facility Open Door Forum call to not hold out until the deadline in order to see if there are “errors and issues” and leave time for corrections if needed.

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Mongan, Emily. “CMS Urges More Provider Diligence on PBJ Data; Notes Nursing Home Compare Update.” McKnight’s Long-Term Care News, 24 Mar. 2017, www.mcknights.com/news/cms-urges-more-provider-diligence-on-pbj-data-notes-nursing-home-compare-update

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Providers get an ‘A’ for submitting PBJ data, officials say

Around 90% of long-term care providers have submitted electronic staffing data, officials said Thursday.

The Payroll-Based Journal submissions were due Nov. 14 to reflect staffing data from July 1 to Sept. 30. However, the Centers for Medicare & Medicaid Services will accept submissions until Dec. 1 as long as providers are making a “good faith effort,” according to sources on a CMS Skilled Nursing Facilities/Long-Term Care Open Door Forum call Thursday.

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Newman, Elizabeth Leis. “Providers Get an ‘A’ for Submitting PBJ Data, Officials Say.” McKnight’s Long-Term Care News, 18 Nov. 2016, www.mcknights.com/news/providers-get-an-a-for-submitting-pbj-data-officials-say

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PBJ updates make it easier for providers to submit hire, termination, and rehire information

On February 17, 2017, the Centers for Medicare & Medicaid Services (CMS) released two updates to the Payroll-Based Journal, making it easier for providers to submit hire, termination, and rehire information for employees without receiving errors.

These updates, detailed below, are considered a “step in the right direction” by the American Health Care Association (AHCA) in their pursuit, joined by other providers and organizations, to “create efficiencies in the collection of staffing data.”

Hurlburt, Amanda. “PBJ Updates Make It Easier for Providers to Submit Hire, Termination, and Rehire Information.” The Post-Acute Advisor, 23 Feb. 2017. No longer available.

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Don’t punish SNFs for training

The Centers for Medicare & Medicaid Services have made information technology and staff competency a priority for the past five years. In response, skilled nursing facility educators expanded training programs to keep up with increased needs. For example, a Certified Nursing Assistant early detection training program was focused on decreasing re-hospitalizations.

Then in July 2016, the Payroll Based Journal system became mandated. It requires a SNF to deduct the hours CNAs participate in in-service training so that staffing levels will be accurately reflected for the Nursing Compare Five Star Rating reporting. Consequently, SNFs are be penalized for training their staff. That’s despite saving the CMS money by avoiding unnecessary hospital readmissions and improving quality of care.

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Marcus, Jeff R. “Don’t Punish SNFs for Training.” McKnight’s Long-Term Care News, 30 Dec. 2016, www.mcknights.com/blogs/guest-columns/dont-punish-snfs-for-training

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CMS Staff Tracking System Promises More Accuracy

The new payroll-based journal (PBJ) system developed by the Centers for Medicare & Medicaid Services to determine the staffing component ratings in the Five-Star Quality Rating System will likely be “a huge change, [resulting in] a more comprehensive and more accurate” look at a facility’s staffing, Ashkan Javaheri, MD, CMD, said at the AMDA – the Society for Post-Acute and Long-Term Care Annual Conference.

Medical directors’ hours are part and parcel of the new system, and “it’s important to understand that the hours you [record and] submit should be based on your medical directorship duties — on what the facility is paying you to do,” said Dr. Javaheri, assistant professor at the University of California–Davis School of Medicine and head of the geriatric division at Mercy Medical Group–Dignity Health Medical Foundation in Sacramento. “Hours for your patient care are not reportable in PBJ.”

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Kilgore, Christine. “CMS Staff Tracking System Promises More Accuracy.” Caring for the Ages, 1 June 2017, www.caringfortheages.com/article/S1526-4114(17)30196-8/fulltext#relatedArticles

Related CMS and PBJ Resources

To learn more about the details, policies and information in these articles, please review these CMS and PBJ publications.

Cms qso memorandum for pbj
QSO Memo 17-25-NH
Payroll based journal policy manual
PBJ Policy Manual v2.2
Faqs for pbj policy manual
PBJ Policy FAQs Dec '16

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Cutting through the COVID staffing star confusion

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CMS UPDATE: Q2 2020 optional PBJ data due November 14

CMS has announced that Q2 2020 data (January 1 – March 31) is due no later than November 14. The alert was posted on the CMS PBJ portal and reads:

New Q2 Deadline: CMS has established November 14, 2020 as the new deadline for the Q2 2020 data.

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CMS announces end of emergency blanket data waiver for nursing homes

Federal officials said Friday that they are ending an emergency blanket waiver intended to reduce administrative burden on nursing homes amid the continuing COVID-19 pandemic.

The Centers for Medicare & Medicare Services (CMS) said that effective August 14, nursing homes nationwide will again be required to submit staffing data through the Payroll-Based Journal (PBJ) system, which allows the agency to collect “staffing information which impacts the quality of care residents receive,” CMS said in a press release.

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Things to remember when submitting PBJ data

CMS will provide further information as soon as possible but are encouraging facilities to still report data as they are able. There will be no penalties or negative impacts to staffing ratings for not submitting by May 15.

As facilities work to gather the necessary information, here are some reminders to help perform a successful submission:

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PBJ update: Goodbye, self-reported census!

When CMS first implemented PBJ, facilities self-reported their census data for Five-Star staffing calculations. Since April 2018, CMS has automatically calculated the census instead. While facilities could still report their census, CMS did not use the data in its Five-Star staffing calculations.

A January 9 update to PBJ Data Submission Specifications now states CMS will no longer accept any census data in PBJ file submissions.

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Staffing takes a front seat when driving quality of care

In CMS’s new rating methodology, facilities are rewarded for staffing more RNs — and punished when they don’t have enough. Ratings on the staffing domain are based on two measures: the number of RN hours per resident per day and total nursing hours (combined RN, LPN, and nurse aide hours) per resident per day, all pulled from quarterly Payroll-Based Journal reports

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CMS: Hundreds More Buildings Could Receive One-Star Staffing Ratings Under New Rules

The new, stricter skilled nursing staffing standards slated for implementation by the federal government next month weren’t entirely unexpected, but they raise questions about the broader problem of understaffed facilities — and hundreds of buildings could be in the crosshairs.

The drop in the threshold for days without RN staffing wasn’t a surprise to Feige; CMS had hinted at the move in various forums, he told SNN.

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Investing in Staffing Doesn’t Necessarily Lead to Skilled Nursing Profits

Facilities that perform well on their staffing ratings see financial results well below those of national medians according to a webinar hosted by CliftonLarsonAllen (CLA) health care principals Cory Rutledge and Matt Wocken.

With their margins so narrow, SNFs have to be judicious about how they invest their dollars to improve, both Rutledge and Wocken stressed. But no matter what they focus on, they still can’t afford to ignore their ratings.

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